Getting Greater Global Results

Top 10 Lessons Learned from

Companies Screening Internationally

Chapters
Global employment screening is the right thing to do.
The basics every employer should know: what, when and why.
Lessons learned: experience is your best guide.

Written by First Advantage. The enclosed information is not intended as legal advice and
should not be interpreted or relied upon as such. The legislative environment is constantly
changing and you should consult your own legal counsel before taking any action.
Copyright 2013 First Advantage. All rights reserved.

Global employment screening

is the right thing to do.

Heres how to make it easier.

If youre reading this ebook, you get it. Organizations like yours know that
background screening is becoming a service without borders. You simply must
screen the people who work for your organization, no matter where theyre
from or where they work, or you risk the integrity and worldwide credibility of
your company.
Global screening can be very different from U.S. background screening.
Availability of information, and the time and requirements to conduct the
searches are different than what is standard in the U.S. That complexity is what
drove the development of this eBook.
To help you better understand the
basics of global screening as well as
its complexities, were pulling back
the curtain and sharing our global
expertise in a brief series of lessons
learned, along with tips, insights
and recommendations designed
to strengthen your knowledge
base and potentially streamline
and advance your overall global
screening program.

3 Ways Global Screening

is Different than U.S.
Screening
Information, such as criminal
records, credential verifications,
and databases may not be as
available.
Special forms, procedures,
and consent language may be
needed, especially for data
privacy or differing local laws.
Cost and turnaround time can
be much higher than domestic
U.S. screenings.
Despite these differences, there
are screening firms that specialize
in overcoming obstacles. Keep
reading.

The basics every employer

should know: what, when and why.

1. What exactly is a global

background check?
For starters, its not a criminal
record search. A global background
check is a collection of screening
components which may or may
not include a criminal record
check, employment and education
verifications, identity verifications
and others. Sometimes, its as
simple as a reference check.
It involves the verification of
supplied information by an
applicant who has given express
written consent. A typical global
screen may consist of contacting
the employers and schools supplied
by the applicant and conducting
a reasonable criminal check to the
extent possible in that country and
appropriate for that position. If
more information is needed, the
applicant can be asked to supply it.

Top 20 Requested Countries

for Background Checks1
[in alphabetical order]

Australia
Brazil
Canada
Chile
China
France
Germany
India
Ireland
Israel
Japan
Malaysia
Mexico
Nigeria
Pakistan
Philippines
Russia
Singapore
South Africa
United Kingdom (U.K.).
1 Society for Human Resource Managers
2012 International Background
Verifications

The components included in a

global background check should
vary based on the position being
filled, regional and country specific
laws and regulations, cultural
norms, data availability, political
climate and other conditions.

2. When are global checks performed?

Employers perform global background checks when they are:
Hiring an applicant who has spent a relevant time period outside of the
country in which they are seeking a position. Many U.S. employers touch
global screening when they add background searches from outside of the
US to their screening request.
Hiring workers in another country to work in that countrybut outside of
the original country of that companys headquarters.

3. Why do it?
All over the world, employers rely on background screening to verify the
information provided in the job application. This screening may be conducted
by the companys own staff, or, increasingly by third party companies that
specialize in background screening. Unfortunately incidents of job history and
education history falsification are on the rise worldwide. Validating the application
information helps employers obtain and retain quality and competent employees.
Employers in many countries, including the US, have a legal duty to exercise
due diligence in hiring. In the US, an employer can be sued for negligence
if it hires someone who it knew, or in the exercise of reasonable care should
have known, was dangerous, unfit or unqualified for the particular job and it
was foreseeable that someone could be harmed. That same standard of care
applies to employers who hire individuals who live or who have spent time
outside of the U.S. and also for employers making hiring decisions abroad.
Despite many other flavors of why employers perform global screening,
things like industry compliance, ensuring competency, protecting against
physical, legal and financial risk, it often boils down to one salient point:
protecting your global brand reputation. And studies by the Aberdeen group
have shown companies who screen usually obtain quality candidates, see a
decrease in turnover with a higher first-year retention, a decrease in the time to
fill the position, and the candidates are considered top ranked. 2
2

Aberdeen Group Research Brief September 2010

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Lessons learned: experience is

your best guide.

As a world-leading global screening provider, we at First Advantage have

seen, experienced and helped organizations learn how to strengthen their
global screening programs. Apart from working with countless organizations
to establish successful international employment screening programs, we now
have 26 global offices staffed with employees who provide us with unmatched
feet on the street coverage in more locations worldwide than any other
screening provider. In this section, you can tap into the deep expertise weve
acquired over the years and apply these proven insights to initiate or advance
your own global screening program.

Lesson 1. Screen globally to manage media

exposure.
Remember this: no matter how senior or junior the
position or where the position is located, always
screen your employees. All it takes is one unverified
background, and your organization is fodder for the
next media feeding frenzy.
Industry estimates for identifying discrepancies between resumes and verified
experience is high. It happens everywhere from the corporate world to
government agencies. When the discrepancy is due to deliberate falsification by
the candidate, it is not limited to
low level hires. C-suite executives
from top software firms in the U.S.
and China have lied about their
education background, as did a
Estimated percentage of
former deputy CIO of the U.S.
fraudulent applications due
Department of Homeland Security,
to false educational qualificawho purchased her Ph.D. from
tions or experience submitted within Indias IT industry,
a diploma mill. In all cases, the
which boasts an estimated
untruths were discovered after
manpower of 2.5 million.
the individuals were hired and had
influenced their organizations
-Source: First Advantage
employees, goals and objectives.

10% - 12%

Employee-related oversight and fraud, and the ensuing media fallout, has
always been bad for a brand. In todays instantaneous, social media news cycle,
damaging news travels the world in seconds, and even worse, it continues
to thrive and live on in online discussions, videos and blogs. Events related
to your brand become a topic of debate in the 24/7 news cycle and remain
searchable on the Internet for years, or decades, after they occur.
In a matter of days, just one negative event can unravel the sizable, long-term
investment most successful organizations devote toward brand developmenteasily
as much as 50 percent of a marketing budget. Coupled with that, is the added,
unplanned cost to repair the damage, which can soar into the tens or hundreds of
thousands of dollars. Not only can this affect your sales and profitability, but your
future potential to attract future talent and secure existing talent.

Key Takeaway

A simple background check to verify the information supplied by

your global candidates costs far less than the media backlash for
not doing it. Dont skip it.

Lesson 2. Consent matters, no matter the

country.
In the U.S., we have a myriad of state and federal
laws beginning with the Fair Credit Reporting Act
(FCRA), all designed to protect personal consumer
information from being misused in hiring and
financial decisions, and from being shared, used or
stored in ways not approved a candidate. However,
with proper written consent from applicants, in accordance with these laws,
you can get the information you need to conduct a background check.
Similarly, other countries and regions are equally passionate about this cause, if
not more so, and enforce their own consumer protection and data privacy laws.

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This means that consent forms

and requirements vary by country,
and before you start a background
check, you must understand what
exact information is required in a
consent for employment background
screening in the specific jurisdiction.
Otherwise, youll be forced to
backtrack with a candidate, after
initiating a background check, in
order to secure the appropriate
consents. Its an unnecessary step that
delays the hiring process and could
cause you to lose a top candidate to a
competing employer.
Here are some other caveats around
consents.
Different countries have different
requirements for consent language.
If you operate in multiple countries,
one size may not fit all. And a
consent that is appropriate for
US candidates will rarely be
appropriate for candidates residing
outside of the US.

Global Consents
The four primary worldwide privacy
principles listed below serve as an
introduction to the requirements which
should be considered when creating
a consent for global pre-employment
background checks and when
processing these background checks.
OECD (Organization for
Economic Cooperation and
Development) Privacy Principles
found in the OECD Guidelines
on the Protection of Privacy and
Transborder Flows of Personal
Data, promoting privacy
protection across the world
(http://www.oecd.org/sti/ieconomy/oecdguidelinesontheprotectionofprivacyandtransborderflowsofpersonaldata.htm)
EU Directive, covering the
European Union
APEC (Asia Pacific Economic
Cooperation) Privacy Framework
PIPEDA (Personal Information
Protection and Electronic
Documents Act), covering the
private sector in Canada when
not covered by substantially
similar provincial legislation and
certain transborder transactions.

Some countries require specific

language to be included in the
notice and consent if personal
information is to be transferred
out of the home country. If your
candidate is in one country and
your background screening takes place in another country, make sure
you follow these requirements. And dont forget even when doing your

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own verifications, you may be transferring personal information across a

country border, for example when you are checking for foreign school or
employment history.
Ensure your candidate consent and disclosure forms are translated into the
appropriate languages, as this is a regulatory requirement in some countries.

Key Takeaway

Accelerate the screening process while complying with global

privacy regulations by doing your research and
knowing what consents and processes are required in a country
before initiating a background check.

Lessson 3. Even data needs a passport.

Global background checks involve the collection and
transmission of personal information and sensitive
data across international borders. As a result, the
background checks are subject to data protection
laws of many countries.
Many countries have privacy and data security
regulations and their regional privacy regulations, such as the EU Directive, can
serve as a high level overview of the requirements of that region. The OECD Privacy
Principles are a good foundation to understanding privacy regulations in general.
Other countries have unclear laws or no regulations at all. For the most part,
countries typically fall into one of several categories:
Strong data privacy and security regulations include members of the
European Union (EU), Argentina, Brazil, South Africa, Australia, South Korea,
and Canada. You should manage background-screening programs with
strict regulations in these jurisdictions by following in-country regulations.

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In some of these countries, such

as the UK and Canada, guidance
is available from government
resources regarding vetting and
screening.

Quick Links
The OECD Guidelines on
the Protection of Privacy and
Transborder Flows of Personal Data
are the foundation of many privacy
guidelines and regulations. Take a
peek at the OECD Privacy Principles
(hyperlinked below) for a better
understanding general privacy
requirements worldwide.

Moderate data privacy and

security regulations or no
country-wide regulations. These
countries may be developing
privacy regulations or may rely
on constitutional statements to
OECD Privacy Principles
govern the rights of a candidate
OECD Guidelines on the Protection of Privacy
with respect to screening.
and Transborder Flows of Personal Data
There may be a lack of clarity
with regards to background
screening. Other countries may not have country wide privacy regulations
but have regulations governing certain sectors, such as information
technology, which can encompass the background screening process.
There may be sectoral requirements or guidance available as there are
in China and India. And there may also be very specific requirements to
conduct certain screens for certain positions.
No privacy regulations. There are still some countries, generally the less
developed countries or those without a strong EU influence, that have
no privacy regulations or constitutional guarantees for privacy. But these
countries are becoming fewer and fewer. Its best not to assume that a
country lacks all privacy protections.
You should be aware of the cross border data transfer requirements in each
jurisdiction. The act of sending emails with personal data, such as spreadsheets
of individuals to be background screened, may easily fall within the countrys
data transfer restrictions if they contain personally identifiable information
and may require additional handling such as obtaining consents from the data
subjects and encrypting the data prior to the transfer.

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Key Takeaway

To cover your bases, follow the basic principles of the OECD or the
more conservative regulations like the EU Data Protection Directive.
Include candidate consent, single purpose of data, security of data
transfer and destruction of data process. In addition, work with a
sophisticated screening provider that supports the secure handling
of sensitive information by offering value-added capabilities, such
as automatically purging sensitive information when its no longer
needed.

Lesson 4. Outsourcing verifications makes

sense.
Outsourcing your global verifications may not be top
of mind, especially if hiring is unstable and budgets
are tight. Yet, thats precisely when it makes the most
sense, as your ability to efficiently find and vet the
most competent, high-quality employees from around
the globe is more important than ever.
For starters, you immediately acquire the global reach of a qualified screening
provider, without respect to time zones, language variances, and cultural
differences, which can be a challenge for internal resources.
More importantly, you also acquire the screening providers global expertise,
which can save you time in more ways than one. First, you can stop chasing
after consent forms by working with a provider that can identify all required
documentation and inquiry information needed before performing the
verification. Likewise, its much more efficient to use a team of professional
verifiers who are strictly dedicated to the task, as opposed to internal
resources who are also juggling other responsibilities. Local teams with global
expertise mean you wont run afoul of local screening norms and can secure

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reliable, accurate and extensive

information from around the world
for each of your hires.
Outsourcing also fosters a consistent
process with more reliable results. For
instance, one person on your internal
team might make three attempts to
contact a previous employer, while
another only tries once. Experienced
screening providers follow a strict,
pre-approved process, conduct
the verifications in a consistent
manner from person to person, and
document the attempts and results.
Likewise, they use approved scripts
to ensure you get the most in-depth
and consistent results. Consistency
of a global program is difficult to
achieve internally, but easy for a well
established provider with global reach
and technology.

SHRM Weighs In
According to the Society for Human
Resource Management, here are
two good reasons to outsource
certain subprocesses within human
resources, including background
checks and verifications.
1. The function is inherently complex
or carries with it legal compliance
risks that are disproportionate to
the volume of activity.
2. The function can be provided
on a cost-effective basis
by leveraging relatively
low volumes within your
organization in combination
with the much greater scale
of activity performed by the
vendor across all of its clients.
http://www.shrm.org/hrdisciplines/pages/
cms_019456.aspx

Key Takeaway

Unless your core competency is performing global verifications,

which it likely isnt, consider outsourcing this complex and
time-consuming task. It will save you time and provide you
with faster, more consistent and reliable results. Also, when
evaluating screening providers, look for firms that offer oneworld processing, meaning regardless of where the verification is
performed from Afghanistan to Zimbabwethe same process is
used, keeping in mind local norms.

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Lesson 5. Does can always equal

should?
Does the fact that you have the ability to acquire
certain data mean that it should be used for
employment purposes? Not necessarily.
For example, you could easily hire an attorney to
visit the courts in Germany to obtain criminal record
information about a job candidate on your behalf. However, this is generally not
considered an allowable process for employment purposes in Germany.
Heres another scenario. Say you have a candidate who lived in the U.S., but
now lives in Mexico, and is applying for a highly supervised job with no access
to cash or sensitive information. While you can perform a U.S. criminal record
check, should you? For that position, in that country?
The point is, extenuating
circumstances matter, and not
considering them could cause
you to spend time and money
on unnecessary components of
a background check, or put your
organization in violation of local laws,
regulations and guidelines.
Before initiating a global background
check, you should always stop to
consider the situation and determine:
What screening components
make the most sense based on
the position being filled
What data restrictions or
limitations and employment
screening guidelines are in
effect within the country being
searched

See the Differences

Below are examples of differing
country specific guidelines on
employment screening.
Australia
Employment screening handbook (HB
323-2007)
Employment screening (AS 4811-2006)

Canada
Canadian Human Rights Commission
Guide to Screening

Ireland
Ireland (Republic of) Data Protection
Commissioner Employee Vetting Guidance

United Kingdom
Information Commissioners Office (ICO)
Employment Practices Guides
CPNI (Centre for the Protection of National
Infrastructure) Pre-Employment Screening

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Key Takeaway

When performing global background checks, take the time to be

strategic and consider the individual components included in the
check and potential country specific compliance issues, as it will
save you time and headaches down the road. More sophisticated
screening providers can help in this area by recommending
position-specific screening packages, and offering an automated
method within their global screening platform that only allows
you to choose searches that are generally allowable for
employment screening within a country.

Lesson 6. Know your options.

In the U.S., we have extensive access to public and
private databases to aid in key screening tasks such as
criminal record checks and employment verifications.
However, outside the U.S., most other countries dont
have publicly searchable databases for background
checking, if they have them at all.
Yet, there are some notable
exceptions and you should
understand and be aware of these
valuable resources such as the
National Skills Registry and Global
Terror and Sanctions Lists.
The National Skills Registry
(NSR). This a national
database of registered and
verified knowledge workers
in the IT industry. Data

Global Screening
has doubled for First

Advantage in the past 5 years

growing from 3+million in 2009
to 7.6 million in 2012.

Nearly a third of the background

checks we perform today contain
requests for information outside of
the United States.

17

fields include permanent fact sheet of information on the professional

along with photographs and appropriate background checks (where
undertaken). Biometrics are also included to ensure unique identification.
Global Terror and Sanctions Lists: Government published lists of persons
designated under its various sanctions programs as known threats.

Key Takeaway

Although the availability and accessibility of databases for the

purposes of employment-related background checks is extremely
limited outside the U.S., resources do exist and you should use them.
To further accelerate and streamline the usage of these databases,
work with a screening provider that has approved access to the
database resource, or is an authorized reseller.

Lesson 7. Benchmark your performance.

Global employment screening is a dynamic, everchanging process due in part to evolving technologies
and expanding regulations and laws around consumer
protection and data privacy. As a result your program
could experience dramatic shifts in performance due to
circumstances beyond the control of your candidates,
your organization or your screening provider.
Because of these changes, you need a mechanism for evaluating your program
performance and driving improvements that keep that performance aligned
with market standards.
Global Screening Trend Reports are available from sophisticated screening
providers to help organizations benchmark their program against that of other
employers. By drawing on a subset of customer background checks performed

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within a specific time frame,

providers can show the most popular
component types (criminal record
search, employment verification,
etc.), and which industries within
a country are performing more
background checks than others.
Likewise, they can reveal average
background check discrepancy rates
by region, country and component,
and much more.

Request a Report
Ask your provider for analytics to
drive program efficiency:
Turnaround time analysis
Order volume
Typical reasons for missing
information delays
Top reasons for candidate
disqualification

Your screening provider should

provide you with access to analytics
about your global screening activity, which you can then compare to the
broader market trend reports. Question areas where your performance has
dropped compared to the market, and work with your provider to resolve the
issue through updated technology, products or other strategies. Likewise,
regrouping with your screening provider to review historical activity provides
the big-picture insight you need to make proactive program improvements
based on your organizations key goals and objectives.

Key Takeaway

You simply must benchmark your program performance against

other organizations to get big-picture insights that help you
recognize and proactively address emerging issues within your
global screening program. Premium screening providers that
support numerous customers with global programs can serve as
a one-stop shop for all your international needs by offering you
comprehensive screening services, trusted global guidance and
trend reports for strategic market insight.

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Lesson 8. Dont play the legal blame game.

With global employment screening comes the onerous
responsibility of knowing whats legal where. Depending
on the scope and reach of your program, it can quickly
seem like an all-consuming, if not impossible task.
Consider this: experienced global screening providers
offer exactly thatexperience. But, its not legal
advice. All quality screening providers will ultimately, and correctly, assign this
responsibility to the customer. Possessing legal expertise around what personal
information is accessible and permissible for employment screening purposes
in 238 countries is simply outside the core competency of most screening
providers. If it were included, global
screening would become costWith mobility of workers
prohibitive for most organizations.
It is strongly recommended that
you consult with in-house or outside
legal counsel when developing
and managing a global screening
program to determine what is legally
allowable and sufficient for the
jurisdictions in which you operate.
Often, full and proper compliance
involves a mix of local and regional
regulations, which further emphasizes
the need for professional legal
guidance. Likewise, the regulations,
guidelines and laws that affect global
employment screening are quickly
changing around the world, and a
qualified legal resource can track
these developments and help your
organization stay up-to-date and
compliant.

across international borders,

more employers need to
consider global background
checks
According to recent U.S.
government statistics:
12.5 percent of the current
population consists of
immigrants.

In 2009, more than 1.1

million persons became Legal
Permanent Residents (LPRs) of
the U.S.
Many workers are from other
countries, or in U.S. on work
visas.
Many U.S. citizens have spent
time abroad.
Many U.S. companies have
offices/facilities abroad.

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Key Takeaway

Work with your legal counsel early and often when performing
international background checks. In the end, it is the employer
who will be held accountable for violation of local and regional rules,
regulations, guidelines and laws. However, your vendor should be
able to help you prepare or forewarn you of concerns to keep you
out of troubled territory. Your vendor should be your guide with your
in-house legal counsel to help you gain a solid understanding of
international data privacy laws and their applicability to employment
screening, as well as what is customary for background screening in a
particular country.

Lesson 9. Know where the buck stops.

When you order a global background check, does
your provider take responsibility for the data it
providescompleting due diligence on any vendors
so that the supply chain meets or exceeds your
standards?
As mentioned earlier, many countries have highly
specific guidelines and rules on how
personal information is handled,
retrieved and transmitted across
Coverage is
borders. Your screening vendor
in the Numbers
should manage this aspect of
clients globally
compliance within their vendor

41,000

network, because ultimately your

organization could be culpable
should any misuse or mishandling of
personal information occur within that
supply chain.

23 million global background

checks annually

26 Office in 12 Countries
21

The more internal resources or feet on the street a screening provider has
throughout the world, the better it can manage quality control and compliance
related to its global screening products. By understanding the scope of a
providers supply chain versus its efforts to place actual employees and branch
offices within other countries, you glean important insights about its experience
level, cultural awareness and country specific compliance knowledge.

Key Takeaway

The more branch offices and employees a screening provider has

across the world, the better they will understand local cultures,
resources and regulations. In turn, it can offer you a stronger level
of global screening oversight that minimizes your risk.

Lesson 10. Get a one-world view.

As you juggle the many language differences, time
zones and local restrictions, the last thing you need
is the administrative nightmare of managing multiple
logins, passwords and reports for separate websites.
Using advanced online technologies, some screening
providers have created a smarter user interface that
unifies all global screening activities under one login, one password.
Regardless of the country being searched, all activity can be initiated and
managed using just one account that offers multi-lingual capabilities to support
employees ordering reports from other countries and your candidates who may
need to provide their data in a relevant local language.
In addition to being easier, a centralized view also supports strategic tasks
such as program management and improvement. Since activity for multiple
countries and regions is managed under one login, real-time metrics are

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accessible in a matter of clicks to

show details around component
types, countries, hit rates,
verification discrepancies and more.

Analytics Means Answers

One, multi-lingual product helps
ensure a clear picture of overall
program performance.
You can only get quick,
comprehensive analytics, when one
system monitors and reports out
what is happening.

Key Takeaway

Do your research and dont settle for the status quo when it comes
to global screening technology. Quality screening providers are
investing millions to deliver innovative solutions that simplify the
global screening process and give you easier, faster and more
cost effective access to the information you need for stronger
international hiring decisions.

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Moving forward
As more organizations expand their search for talent to a worldwide scale, its
more important than ever to screen your candidates with a global process.
Efficiently and effectively screening international candidates gets quickly
bogged down and complicated by things like time zones, language differences,
consent forms, local and regional data privacy laws, cultural norms and more.
Apart from increasing your familiarity with country specific employment
screening guidelines, localized screening resources and cultures, your best bet
for developing and managing a successful global screening program is to work
with a qualified screening provider. The right provider can scale your program
to meet your precise needs, while offering proactive guidance and automated,
centralized solutions that help you quickly, cost-effectively and accurately screen
and hire the best candidates from around the world.

Questions?
Contact First Advantage
Call 866.400.3238
Email tas@fadv.com
Visit www.fadv.com

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Written by First Advantage. The enclosed information is not intended as legal advice and
should not be interpreted or relied upon as such. The legislative environment is constantly
changing and you should consult your own legal counsel before taking any action.
Copyright 2013 First Advantage. All rights reserved.

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